Spinosa Order on Plaintiff 's Motion to Compel Discovery

Similar documents
Order on Motion to Amend Counterclaim, Add Counterclaim Defendants, and Conduct Additional Discovery (SATISH S. LATHI)

In the Court of Appeals of Georgia

Order on Defendants Heiman and Sussex's Motion to Dismiss (CURTIS LEE MAYFIELD, III)

Order on Defendant Elkik's Motion for Summary Judgment (PAYLESS CAR RENTAL SYSTEMS, INC.)

Order on Smart Games' Motion to Dismiss (MICHAEL MACKE)

Order on Plaintiff 's Motion to Compel (MICHAEL MACKE)

Alliance Bank & Trust Company ( Alliance Bank ) ( First Motion to Compel ); Plaintiffs

Reading Room. Georgia State University College of Law. Melvin K. Westmoreland Fulton County Superior Court Judge. Georgia Business Court Opinions

No. PLAINTIFF S ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND REQUEST FOR PRODUCTION OF DOCUMENTS. Plaintiff, MIKE complains of defendants STEPHEN and

In The Court of Appeals Fifth District of Texas at Dallas. No CV. DFW ADVISORS LTD. CO., Appellant V. JACQUELINE ERVIN, Appellee

Hammond v Smith NY Slip Op 50670(U) Decided on April 22, Supreme Court, Monroe County. Rosenbaum, J.

Scaglione v Castle Restoration & Constr., Inc NY Slip Op 33727(U) April 27, 2010 Sup Ct, Queens County Docket Number: /09 Judge: Orin R.

Order on Plaintiffs' Motion In Limine to Exclude Portions of the Expert Testimony of Andrew Miller (ING USA ANNUITY AND LIFE INSURANCE COMPANY)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION CIVIL ACTION NO. 1:11-CV RWS

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA RULE 5.2 CERTIFICATE

CONTRACTS AND SALES QUESTION 1

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT STATE OF HAWAII ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

Order on Harrison and Katten's Motion for Judgment on the Pleadings and Motion for Reconsideration of Dismissal Orders (CURTIS LEE MAYFIELD, III)

Order on Plaintiffs' Motion In Limine to Exclude Rebuttal Expert Testimony of Robert Daines (ING USA ANNUITY AND LIFE INSURANCE COMPANY)

Rudy Blake Frazier and Building Technology Consulting LLC Order on Defendants' Motion to Dismiss

ARTIST MANAGEMENT CONTRACT

Filing # E-Filed 07/11/ :27:15 PM

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA : : Civil Action No.

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT WITH ALL DEFENDANTS, MOTION FOR ATTORNEYS FEES AND SETTLEMENT FAIRNESS HEARING

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Order on Defendants' Motions to Exclude Testimony of Plaintiffs' Expert Charles Phillips (AMANA I SA)

Order on Motion to Exclude Testimony of David A. Duffus (JAMES & JACKSON LLC)

Case 1:14-cv FDS Document 24 Filed 06/26/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. ) ) Civil No. v.

August 30, A. Introduction

Unreported Disposition 56 Misc.3d 1203(A), 63 N.Y.S.3d 307 (Table), 2017 WL (N.Y.Sup.), 2017 N.Y. Slip Op (U)

Order Regarding Disbursement and Setting Post- Judgment Interest Rate (LARRIE GRANT PLYMEL)

v No Wayne Circuit Court

FILED: KINGS COUNTY CLERK 04/21/ :00 PM INDEX NO /2015 NYSCEF DOC. NO. 88 RECEIVED NYSCEF: 04/21/2017

Wald v Graev 2014 NY Slip Op 32433(U) September 15, 2014 Supreme Court, New York County Docket Number: /2013 Judge: Saliann Scarpulla Cases

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION. Civil Action FILE No. 1:00-CV-1416-CC

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) MEMORANDUM OPINION

IN THE COURT OF APPEALS OF THE STATE OF OREGON

Case 1:18-cv Document 1 Filed 04/26/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 2:16-cv JAR-JPO Document 69 Filed 09/20/17 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Follow this and additional works at:

Mardi Harrison v. Bernard Coker

Worth Constr. Co., Inc. v Cassidy Excavating, Inc NY Slip Op 33017(U) January 10, 2014 Sup Ct, Westchester County Docket Number: 61224/2012

Case 2:09-cv CMR Document Filed 03/14/14 Page 1 of 24 EXHIBIT A-1

Goodman v MHP Real Estate 2015 NY Slip Op 31965(U) October 21, 2015 Supreme Court, New York County Docket Number: /2015 Judge: Saliann

Order on Motion for Judgment on the Pleadings (DEBORAH EAVES)

Is there a contract?

No IN THE SUPREME COURT OF THE STATE OF MONTANA 2004 MT 15

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION. CIVIL ACTION NO. v. 1:12-cv-0686-JEC ORDER & OPINION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

In the Court of Appeals of Georgia

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGIA PLAINTIFFS' RESPONSE TO DEFENDANT NARCONON OF GEORGIA'S MOTION TO COMPEL

BSL Holdings, LLC et al., Order Granting in part and denying in part Defendants' second renewed partial motion to dismiss

NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION

Instructions on filing a claim:

Barbara King Family Trust v Voluto Ventures LLC 2005 NY Slip Op 30157(U) August 24, 2005 Supreme Court, New York County Docket Number: /2004

CITY OF ATLANTA, SPRING STREET (ATLANTA), LLC, as Purchaser. THE ATLANTA DEVELOPMENT AUTHORITY, as Purchaser DRAW-DOWN BOND PURCHASE AGREEMENT

NOTICE OF (i) PROPOSED SETTLEMENT OF CLASS ACTION, (ii) REQUEST FOR REIMBURSEMENT OF ATTORNEYS EXPENSES, AND (iii) SETTLEMENT FAIRNESS HEARING

Starlite Media LLC v Pope 2014 NY Slip Op 30984(U) April 11, 2014 Supreme Court, New York County Docket Number: /2010 Judge: Eileen Bransten

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Senate Bill No. 72 Senators Care and Amodei

Rosenberg v Hedlund 2016 NY Slip Op 30191(U) February 3, 2016 Supreme Court, New York County Docket Number: /2015 Judge: Eileen A.

Case 1:14-cv ODE-LTW Document 1-1 Filed 10/30/14 Page 2 of 10. IN THE SUPERIOR COURT OF FULTON co~fju;q01~!1f~~ffl STATE OF GEORGIA

Follow this and additional works at:

Order ( JOHN BEASLEY)

Supplement to Report on Legal Opinions to Third Parties in Georgia Real Estate Secured Transactions

Court of Appeals. First District of Texas

DEFENDANT S RESPONSE TO PLAINTIFF S FIRST AND CONTINUING INTERROGATORIES

FILED: NEW YORK COUNTY CLERK 06/02/ /15/ :56 02:55 AM PM INDEX NO /2015 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 06/02/2015

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS. Case No. 1:14-cv NOTICE OF CLASS ACTION SETTLEMENT

Order on Motion to Set Aside Final Judgment ( JOHN BEASLEY)

)

Case 2:05-cv CNC Document 119 Filed 07/13/2006 Page 1 of 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN. v. Case No.

Submit a Claim Exclude Yourself Object Go to a Hearing Do Nothing

v. Record No OPINION BY JUSTICE CYNTHIA D. KINSER JUNE 7, 2002 LINDA D. SHAFER

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. No. 3:15-cv EMC

APPENDIX I SAMPLE INTERROGATORIES

NOTICE OF PENDENCY AND PROPOSED CLASS ACTION SETTLEMENT

Obeid v Bridgeton Holdings, LLC 2015 NY Slip Op 31085(U) June 24, 2015 Supreme Court, New York County Docket Number: /2015 Judge: Saliann

Order on Harrison and Katten's Motion for Reconsideration of Dismissal Orders (ALTHEIDA MAYFIELD)

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION

v. Docket No Cncv RULING ON MOTIONS TO DISMISS AND MOTION TO STRIKE

2:16-cv SJM-RSW Doc # 19 Filed 08/31/17 Pg 1 of 9 Pg ID 349 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Information or instructions: Combined discovery requests, admissions, production of documents and interrogatories

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

March 22, Supreme Court. No Appeal. (PC ) John Broccoli : v. : Walter Manning. :

FILED: NEW YORK COUNTY CLERK 02/06/ :34 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/06/2017

Case 1:13-cv PAB-KMT Document 98 Filed 01/20/16 USDC Colorado Page 1 of 19

DECISION AND ORDER. Ford Motor Credit Company ( Ford ) has filed a Complaint for Foreclosure

Nathan v. Matta et al. Shareholder Litigation c/o GCG PO Box Dublin, OH

OPERATING AGREEMENT OF AAR ROCKY MOUNTAINS GREAT PLAINS REGION, LLC ARTICLE I DEFINITIONS

Astor Place, LLC v NYC Venetian Plaster Inc NY Slip Op 31801(U) September 28, 2016 Supreme Court, New York County Docket Number: /15

Case 0:14-cv WPD Document 28 Entered on FLSD Docket 09/05/2014 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

1 08..PV_3142 FILED IN CLERKS OFFICE OCT ("SLUSA"), 15 U.S.C. 78bb(f), and, thus, Plaintiffs' claims should be dismissed.

Representative or Custodian Name (if different from Beneficial Owner(s) listed above) City State ZIP Code

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE, CENTRAL JUSTICE CENTER ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )_ ) ) ) ) )

Jong Yien Ho v Li Yu Yen 2017 NY Slip Op 32732(U) November 13, 2017 Supreme Court, Queens County Docket Number: /2017 Judge: Marguerite A.

Bylaws of The San Francisco Maritime National Park Association. A California Nonprofit Public Benefit Corporation

Transcription:

Georgia State University College of Law Reading Room Georgia Business Court Opinions 10-8-2015 Spinosa Order on Plaintiff 's Motion to Compel Discovery Alice D. Bonner Fulton County Superior Court Follow this and additional works at: https://readingroom.law.gsu.edu/businesscourt Part of the Business Law, Public Responsibility, and Ethics Commons, Business Organizations Law Commons, and the Contracts Commons Institutional Repository Citation Bonner, Alice D., "Spinosa Order on Plaintiff's Motion to Compel Discovery" (2015). Georgia Business Court Opinions. 362. https://readingroom.law.gsu.edu/businesscourt/362 This Court Order is brought to you for free and open access by Reading Room. It has been accepted for inclusion in Georgia Business Court Opinions by an authorized administrator of Reading Room. For more information, please contact mbutler@gsu.edu.

Fulton County Superior Court ***EFILED***KB Date: 10/9/2015 11:08:30 AM Cathelene Robinson, Clerk IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA TOMMY SPINOSA III, ) ) Plaintiff, ) ) v. ) ) Civil Action File No. 2014-CV-254988 H. BRADFORD INGLESBY, VALERIE ) INGLESBY, and CRESCENT ) INVESTMENT GROUP, LLC, ) ) Defendants. ) Order on Plaintiff's Motion to Compel Discovery The Court, having considered Plaintiff's Motion to Compel Discovery and the response thereto, finds as follows: Plaintiff Tommy Spinosa ("Spinosa") began as an employee of Gross Capital Advisors while Defendant H. Bradford Inglesby ("Mr. Inglesby") was Gross Capital Advisors' managing partner. Spinosa alleges that, beginning in early 2014 and continuing over several months, Mr. Inglesby recruited Spinosa for a new real estate investment firm, which eventually became Crescent Investment Group, LLC ("CIG"), by promising Spinosa equity ownership and misrepresenting Gross Capital Advisors' financial condition. CIG was formed as a Georgia limited liability company on May 13, 2014 and Spinosa left GCA in June of 2014 to join GIG. After CIG was formed but before Spinosa began working at GIG, GIG and Fortress Investment Group entered into a joint venture. Defendants state that under the joint venture agreement, GIG, through Mr. Inglesby as its sole member and principal, would source real estate investments for potential acquisition by subsidiary vehicles owned by Fortress and entities controlled by Mr. Inglesby. After acquisition, GIG would

be responsible for property management services. According to his Complaint, Spinosa alleges that he left GCA and joined CIG because he was promised a 25% ownership interest in CIG. After Spinosa joined CIG, Mr. Inglesby allegedly changed the deal. Spinosa alleges that the parties came to an agreement on a compensation plan in July 2014 that made him a 12.5% member in CIG and provided an annual salary and bonus structure, profit sharing, and a "partnership" distribution. The bonus was to be based on the "Gross Acquisition Fee" that CIG received for each investment that it closed. Although Spinosa states the parties came to an agreement on the compensation plan and he accepted, Defendants refused to memorialize the terms in a written agreement. Spinosa contends he was the point man on the Lenox Park transaction, the acquisition of an office park located in Buckhead, which closed on October 3, 2014. Spinosa also claims he brought in several investors who contributed $2.5 million. Yet, Spinosa was terminated from CIG on October 20,2014, without being compensated for his role in the deal, including a bonus valued by Spinosa to be more than $500,000. This suit followed. Spinosa seeks production of three categories of documents from Defendants H. Bradford Inglesby, Vanessa Inglesby, and Crescent Investment Group ("CIG") that Spinosa asserts Defendants refuse to produce. These categories are (1) emails and documents concerning the formation of CIG, including Fortress's involvement, (2) emails and documents concerning the Lenox Park transaction, and 3) documents concerning CIG's finances. Generally, Defendants note that they have produce 2,432 pages of responsive documents. Defendants also argue that Spinosa covertly copied

and maintained his entire CIG email account mailbox with over 90,000 pages of emails and a large quantity of CIG corporate records that were maintained in cloud-based data storage, including 34,000 pages from a "Lenox Park" subfolder. Plaintiff produced his CIG emails and the Lenox Park subfolder documents to Defendants. "Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action... It is not ground for objection that the information sought will be inadmissible at the trial if the information sought appears to be reasonably calculated to lead to the discovery of admissible evidence." O.C.G.A. 9-11-26(b)(1). In defining relevancy, the Supreme Court of Georgia recently stated, "in the discovery context, courts should and ordinarily do interpret 'relevant' very broadly to mean any matter that is relevant to anything that is or may become an issue in litigation." Bowden v. Medical Center, Inc., 773 S.E. 2d 692, 696 (2015) (quoting Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 n. 12 (1978) (internal quotation marks omitted). 1. Documents Concerning the Formation of CIG and Fortress's Involvement in CIG's Formation Spinosa requested from CIG: 1 Documents "concerning or relating to the management, operation, or potential investment of ownership in, Defendant." (Request No. 11); Documents "submitted to or received from any banks, financial institutions or other persons, including Fortress Investment Group ("Fortress"), 1 Although the Motion seeks to compel documents from all three Defendants, the Requests sent to CIG are not identical to the Requests sent to Mr. and Mrs. Inglesby and Plaintiff does not distinguish between the two in his motion. For the purposes of this Motion to Compel then, when Plaintiff refers to a specific Request Number, the Court will assume he means the Request to CIG.

concerning or relating to any monies loaned or paid to Defendant (Request No. 12); Documents "concerning or relating to the formation or organization of Defendant" (Request No. 16); "Any correspondence concerning or related to any joint venture agreement or other relationship between Defendant and Fortress" (Request No. 22); and Documents "concerning or relating to any joint venture agreement or other relationship between Defendant and Fortress" (Request No. 23). Spinosa argues that this discovery is relevant because it could show that at the same time Mr. Inglesby was promising Spinosa he would be a member holding a 12.5% stake Mr. Inglesby was representing to others, including Fortress, that CIG would be a sole proprietorship. Spinosa claims this is relevant to his fraud claim (whether he knowingly made misrepresentations to induce Spinosa to join CIG), as well as his breach of fiduciary duty, unjust enrichment, attorneys' fees, and punitive damages claims. Spinosa also asserts that the documents are relevant to Mr. Inglesby's credibility by showing that he was acting contrary to his assertions to Spinosa regarding his partnership interest. In response, Defendants contend the oral agreement upon which Spinosa bases his claims arose two months after the formation of CIG and therefore the circumstances surrounding CIG's formation are irrelevant. Thus, they have limited production to the Certificate of Organization, the Articles of Incorporation, the LLC Agreement, the Application for an EIN, and the Joint Venture Agreement between CIG and Fortress.

Defendants argue that these documents show the undisputed and established fact that Inglesby had the intent to form CIG with himself as its sole member in May 2014 and that the discovery of more documents is not necessary. Defendants further argue that documents predating the formation of CIG could not be relevant to Spinosa's breach of fiduciary claim because Spinosa does not allege that he was made partner until July 2014, well after CIG was formed. The Court finds that Defendants should be compelled to produce all emails and documents related to the formation of CIG and Fortress's involvement in CIG's formation. Spinosa asserts that Mr. Inglesby recruited him over several months in part by telling him he would be a partner and 12.5% owner of CIG. Those months fall both before and after the formation of CIG. Communications regarding the formation of CIG with Fortress and others could show that Mr. Inglesby was making misrepresentations to Spinosa. In such, discovery of the requested documents is relevant at a minimum to Spinosa's fraud claim and Plaintiff's Motion to Compel as to these requests to CIG is GRANTED. 2. Documents concerning the Lenox Park transaction. Spinosa requested from CIG: 2 Documents "concerning or related to the Lenox Park, AT&T Lenox, AT&T Lindbergh, Gas Station, Palmetto Bluff transactions." including Defendant's gross or net acquisition fees and any potential back-end promote distribution for such transactions (Request No. 31); and 2 See Footnote 1. 3 The parties do not identify the relevance of any of these entities other than Lenox Park.

"All correspondence between (1) Defendant, Mr. Inglesby, Mrs. Inglesby, Plaintiff, or any other employee, principal, member or agent of Defendant, and (2) Columbia Property Trust ("Columbia"), Jones Lang LaSalle ("JLL"),4 or Fortress, concerning or related to the Lenox Park, AT&T Lenox, AT&T Lindbergh, Gas Station, Palmetto Bluff transactions." (Request No. 32). Spinosa contends that the Lenox Park transaction should have played a significant part in his bonus compensation. He alleges that he was not paid a bonus because Mrs. Inglesby claimed that Mr. Inglesby did all the work on the deal. He asserts that documents and emails related to the Lenox Park deal will show that Spinosa did all the work, which would be relevant to prove justifiable and detrimental reliance in support of his fraud and promissory estoppel claims, and disprove that Mr. Inglesby did all the work. Spinosa also asserts that the documents will be relevant to his damages and the validity of offsets and expenses deducted from the "gross acquisition fee" that purportedly would form the basis of his bonus and his quantum meruit and unjust enrichment claims. Spinosa also seeks any documents that support Defendants contention that Fortress requested that the acquisition fee be reduced which would inevitably affect Spinosa's earned bonus. Defendants counter that they have produced all the relevant documents, including: a series of agreements executed at closing by CIG, the closing statement for the transaction, the property management agreement, a manag.ement agreement between the Lenox Park Owners Association, CIG, and the owner entity, an agreement that outlined incentive compensation payable to CIG in connection with Fortress 4 The parties do not identify the relevance of these two entities.

investment in the property, a restated partnership agreement for a CIG-formed entity that entities CIG to additional fees for managing this investment, and emails related to the transaction, including Spinosa's work on the transaction. Defendants contend that these documents reflect the totality of the economics that have been paid or could be paid to CIG or its affiliates as a result of the Lenox Park transaction. Defendants assert that other types of documents specifically requested by Spinosa, like "HUD forms," "base case overviews," or "supportive renewal rationales" are not relevant to his claims. Lastly, Defendants argue Spinosa is not entitled to further documents because he does not show how additional documents would be relevant and because he took all the relevant documents when he was terminated. The Court finds that Defendants should be compelled to produce any emails or documents concerning the Lenox Park transaction other than those on which Spinosa was copied or has produced to Defendants. These documents could show Spinosa's role in the transaction and Defendants' communications regarding Spinosa and the transaction at the relevant time. Therefore, they could lead to admissible evidence regarding what Spinosa's compensation should have been. In addition, discovery of the requested documents is relevant at a minimum to Spinosa's damages and Plaintiff's Motion to Compel as to these requests to CIG is GRANTED. 3. Documents concerning CIG's finances. Spinosa requests from CIG: 5 Documents "concerning or related to Defendant's revenues, income, expenses, profits, assets, liabilities, net worth, or its business and financial condition" 5 See Footnote 1.

(Request No.6); "Defendant's monthly bank statements, cancelled checks, check stubs, deposit slips, deposit books, and signature cards for each bank account maintained in the name of Defendant, individually or jointly with any other person or entity." (Request 13); Documents "reflecting monies paid to members or employees of Defendant." (Request 14); "Any... deeds... or other documents... concerning or related to any property in which Defendant has had any interested [sic] or equity." (Request 15); Documents "concerning or related to Defendant's contractual management fees or asset management fees, or reductions or offsets thereto." (Request 27); Documents "concerning or related to Defendant's retained earnings or profit sharing." (Request 28); Documents "concerning or related to Defendant's actual or projected organizational and entity formation expenses,... " and other expenses. (Request 29); and Documents "concerning or related to Defendant's debt service or loan interest." (Request 30). Spinosa argues that CIG has only produced unaudited, one-page financial statements and that more complete financial information is needed to prove damages and understand the full value of Spinosa's share as a member and under the compensation plan. Spinosa notes that the 2014 financial statement lists $726,564 in expenses although a compensation plan drafted by Mr. Inglesby when Spinosa was hired

estimated expenses for June through December of 2014 would be only $425,209. The expenses reported for 2015 were double the estimated expense for the year to date. Spinosa's bonus calculation was based, in part, on when the company reached a "break even" point. Spinosa contends that he should have access to detailed information about GIG's revenues and expenses for this time period, not just a summary. Defendants argue that the requested financial discovery is overly burdensome and contend that the produced profit and loss summaries from Quickbooks include line item revenue and expense detail and disclose CIG's overall financial condition. They contend that producing transaction level support for every expense is not practicable. Instead, Defendants state they have offered to produce more detailed GIG financial records but that Spinosa has failed to compromise to facilitate production. Defendants have proposed three plans to limit financial discovery: (1) To consider only targeted requests by Spinosa for additional documents; (2) To produce detailed copies of GIG's detailed profit and loss statements, provided that Spinosa agree not to seek any further supporting documentation concerning CIG's financial condition; and (3) To produce detailed copies of GIG's detailed profit and loss statements, provided that Spinosa would confine follow-up requests to expenses over $10,000. This case is about the alleged oral agreement on the compensation plan and, if there is found to be an agreement, the amount Spinosa is owed under the compensation plan. The compensation plan factors in a "break even" point based on expenses. Thus GIG's financials during the time of Spinosa's employment would be

relevant to the calculations of damages. The Court will not order CIG to produce every transaction level document related to its expenses at this time, but Defendants should produce the detailed profit and loss detail sheets and will be subject to further targeted discovery. After Spinosa has an opportunity to review the detailed profit and loss reports, he may submit to Defendants a list confined to supporting documentation for any suspect or unusual expenses. If further production is warranted, the Court expects the parties to work cooperatively on this list and production. Plaintiff's Motion to Compel as to these requests to CIG is GRANTED. 4. Spinosa Requests the Court order electronic imaging of Defendants' computers. Spinosa asserts that the Court should order the electronic imaging of the Defendants' work and personal computers so that Spinosa can examine their contents and ensure that all relevant documents have been produced. Spinosa believes this extraordinary request is warranted because he knows about nine emails that are relevant that were not produced, eight of which were sent from Mr. Inglesby's personal Google email account. Defendants argue that the emails were not relevant to any requests or this case. They also assert that they searched Mr. Inglesby's personal email account for responsive emails. Given Defendants' representations, the Court will not order an electronic imaging of computers. This extraordinary relief sought in Plaintiff's Motion to Compel is DENIED.

5. Attorneys' Fees and Extension of Discovery Deadlines Spinosa's request for attorneys' fees in connection with the Motion to Compel is DENIED. Spinosa's request to extend the December 31, 2015 deadline for discovery in this case is DENIED. SO ORDERED this 7 day of October, 2015.

Copies to: Attorneys for Plaintiffs Attomeys for DefeAdants Matthew T. Gomes David Tetrick, Jr. WEINBERG, WHEELER, HUDGINS, John C. Taro GUNN & DIAL, LLC KING & SPALDING, LLP 3344 Peachtree Road, NE 1180 Peachtree Street, N.E. Suite 2400 Atlanta, Georgia 30309 Atlanta, GA 30326 404-572-3526 404-876-2700 dtetrick@kslaw.com mgomes@wwhgd.com jtoro@kslaw.com